'Siri®, How Much Discoverable ESI is on My Smartphone?'
As anyone who has collided with someone staring at their smartphone and not where they are walking knows (known in Yoga circles as the "downward-facing pedestrian"), mobile device usage has exploded in just a few years...

In case you were in doubt, being asked to provide “easily accessible” digital records of thousands of paper documents you already produced may not be considered unreasonably cumulative, duplicative or burdensome, and if the related costs are something like .025% of the amount in controversy...